1. INTRODUCTION AND ACCEPTANCE

Welcome to URCASH Financial Platform Services UK Limited. These Terms of Service ("Terms," "Agreement") constitute a legally binding agreement between you ("User," "you," "your") and URCASH Financial Platform Services UK Limited ("URCASH," "Platform," "we," "us," "our") regarding your use of our innovative peer-to-peer (P2P) lending platform and comprehensive suite of related financial services.

Company Information

Legal Name: URCASH Financial Platform Services UK Limited

Company Registration: 16389705 (England & Wales)

Registered Office: 20 Wenlock Road, London, England, N1 7GU

Contact Information

Legal Email: legal@urcash.co.uk

Phone: +44(0) 808 271 0446

Website: www.urcash.co.uk

Acceptance of Terms

By creating an account, accessing our platform, downloading our mobile applications, or using any of our services, you acknowledge that you have:

  • Read and thoroughly understood these Terms
  • Reviewed and accepted our Privacy Policy
  • Understood the risks associated with P2P lending and investment
  • Agreed to be legally bound by all provisions contained herein

Important Notice

If you do not agree to these Terms in their entirety, you must not use our platform or services. Continued use of our services following any modification to these Terms constitutes acceptance of such changes.

2. JURISDICTIONAL SCOPE AND REGULATORY FRAMEWORK

URCASH operates as a multi-jurisdictional financial technology platform, providing services in strict compliance with the regulatory requirements of each jurisdiction where we operate. Our commitment to regulatory excellence ensures the highest standards of consumer protection and operational integrity.

2.1 Operating Jurisdictions

🇬🇧 United Kingdom

Primary Regulator: Financial Conduct Authority (FCA)

Status: FCA Regulatory application pending for full authorization

Compliance Framework: Consumer Credit Act 2006, UK GDPR, Consumer Duty

Consumer Protection: No Financial Services Compensation Scheme (FSCS) protection

🇪🇺 European Union

Primary Oversight: European Securities and Markets Authority (ESMA)

Compliance Framework: MiFID II, PSD2, AIFMD, EU GDPR

Consumer Protection: National competent authorities

Passport Rights: Cross-border service provision under EU financial services directives

🇮🇳 India

Primary Regulator: Reserve Bank of India (RBI)

License Type: NBFC-P2P (Non-Banking Financial Company - Peer to Peer Lending Platform)

Compliance Framework: RBI Master Direction on NBFC-P2P, Companies Act 2013, DPDPA 2023

Special Services: UR-Gold ornament-backed lending, UR-Medcare healthcare financing

🇺🇸 United States

Federal Oversight: SEC registration, CFPB compliance

State Licensing: Money transmission licenses, lending licenses

Compliance Framework: BSA, AML, Truth in Lending Act, Fair Credit Reporting Act

Consumer Protection: State and federal consumer financial protection laws

2.2 Regulatory Status and Authorizations

Current Regulatory Position

URCASH maintains an active regulatory compliance program with ongoing applications and authorizations in key jurisdictions:

  • UK: FCA Regulatory pending submission for full authorization
  • EU: Preparatory phase for MiFID II investment services authorization
  • India: NBFC-P2P application due for submission to RBI
  • US: SEC registration process due for submission with state licensing applications to be submitted

3. SERVICE DESCRIPTION

URCASH operates a comprehensive financial technology ecosystem that revolutionizes traditional lending and investment through innovative peer-to-peer solutions, advanced technology integration, and multi-jurisdictional regulatory compliance.

3.1 Core Platform Services

💰

P2P Lending Platform

Direct connection between borrowers and lenders, eliminating traditional intermediaries

📈

Investment Facilitation

Diversified portfolio management and automated investment strategies

🔍

Credit Assessment

Advanced AI-driven risk evaluation and credit scoring methodologies

Payment Processing

Real-time transaction management and multi-currency support

🤖

Automated Matching

Intelligent algorithms for optimal lending and investment opportunities

📱

Mobile & Web Platforms

Cross-platform accessibility with real-time monitoring and analytics

3.2 Additional Services Portfolio

UR-IRaaP (Idenity Request Authorization Authentication Payment) Idenity Request Authorization Authentication Payment with technology-driven processes and regulatory compliance.
UR-Forex Deposit Bonds Multi-currency services including forex deposit currency hedging, and international credit solutions.
UR-Gold Ornament-Backed Lending (India) Secured lending solutions to buy gold ornaments.
UR-Medcare Healthcare Financing (India) Specialized lending solutions for healthcare financing for medical treatments and procedures.
Financial Education Platform Comprehensive educational resources, webinars, and advisory services for financial literacy.
Repo Edge Account B2B financial services for cross border lending agains the mortagage deals due to paid off in 12 months.

3.3 Technology Platform Infrastructure

Advanced Technology Stack

Our platform leverages cutting-edge financial technology to deliver secure, scalable, and efficient services:

  • Open Banking Integration: Secure API connections with major banks for real-time financial data
  • Atomikos Technology: Enhanced security and transparency for transaction records
  • AI & Machine Learning: Advanced credit scoring, fraud detection, and risk assessment
  • Multi-Currency Support: GBP, USD, EUR, INR with real-time exchange rate integration
  • Cloud Infrastructure: Enterprise-grade security with 99.9% uptime guarantee
  • API Ecosystem: Third-party integrations with financial institutions and service providers

4. USER ELIGIBILITY AND ACCOUNT REGISTRATION

URCASH maintains strict eligibility criteria to ensure regulatory compliance, consumer protection, and platform integrity across all jurisdictions where we operate.

4.1 General Eligibility Requirements

Age Requirements Minimum 18 years of age in all jurisdictions (21+ for certain lending activities in specific US states)
Legal Capacity Must possess full legal capacity to enter into binding financial contracts and agreements
Identity Verification Government-issued identification and comprehensive KYC verification required
Financial Standing No current bankruptcy proceedings or financial services restrictions
Regulatory Compliance Not subject to sanctions, PEP restrictions, or financial services prohibitions
Technological Access Access to internet, email, and mobile device for platform access and communication

4.2 Jurisdiction-Specific Requirements

UK Specific Requirements

  • Residency: UK resident with proof of address within last 3 months
  • Right to Financial Services: Eligible to participate in UK financial services with a UK Bank Account
  • Consumer Credit Assessment: Affordability assessment under Consumer Credit Act
  • FCA Classification: Customer categorization (retail, professional, eligible counterparty)
  • Income Verification: Minimum income thresholds for lending activities
  • Credit History: UK credit bureau checks and scoring

EU Specific Requirements

  • EU Citizenship/Residency: EU citizenship or legal residency status with a Bank Account in EU
  • MiFID II Assessment: Investor categorization and suitability assessment
  • Tax Identification: Valid EU tax identification number
  • ESMA Compliance: Adherence to European securities regulations
  • Local Regulations: Compliance with national investor protection requirements
  • Language Requirements: Understanding of terms in local EU language

India Specific Requirements

  • Citizenship Status: Indian citizen or Overseas Citizen of India (OCI) status
  • PAN Verification: Valid Permanent Account Number with income tax filing history
  • Aadhaar Verification: Biometric identity verification through Aadhaar system
  • RBI KYC Compliance: Full Know Your Customer documentation as per RBI guidelines
  • Investment Limits: Adherence to RBI-prescribed lending and borrowing limits
  • Bank Account Linking: Indian bank account for transaction processing

US Specific Requirements

  • Legal Status: US citizenship, permanent residency, or valid work authorization
  • Tax Identification: Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)
  • State Compliance: Compliance with specific state lending and investment regulations
  • Accredited Investor: Status verification for certain investment products
  • AML/CIP Requirements: Anti-Money Laundering and Customer Identification Program compliance
  • State Licensing: Verification of state-specific licensing requirements

4.3 Account Registration Process

Multi-Stage Verification Process

Our comprehensive registration process ensures security, compliance, and platform integrity:

  1. Initial Registration: Basic information collection and email verification
  2. Identity Verification: Government ID upload and third-party verification
  3. Address Verification: Proof of residence and address confirmation
  4. Financial Verification: Income documentation and bank account verification
  5. Risk Assessment: Investment experience and risk tolerance evaluation
  6. Compliance Screening: AML, sanctions, and PEP screening
  7. Account Activation: Final approval and platform access grant

Important Compliance Notice

False Information Prohibition: Providing false, misleading, or incomplete information during registration constitutes a material breach of these Terms and may result in immediate account termination, reporting to regulatory authorities, and potential legal action.

5. INVESTMENT AND LENDING TERMS

URCASH facilitates sophisticated investment and lending opportunities through our technology-driven platform, offering diverse financial products designed to meet varying risk appetites and investment objectives.

5.1 Investment Services and Opportunities

P2P Loan Investments Direct investment in individual loans with comprehensive risk profiling and performance tracking
Diversified Portfolios Automated portfolio construction across multiple loans, sectors, and risk categories
Fixed-Term Options Investment periods ranging from 1 month to 2 years with defined maturity dates
Sustainable Finance ESG-compliant investment options with environmental and social impact measurement

5.2 Comprehensive Risk Disclosure

⚠️ Critical Risk Warning

Your capital is at risk. Peer-to-peer lending and investment carries significant risks that could result in partial or total loss of invested capital. Please carefully consider the following risks:

💸 Principal Risk

Capital Loss: Investment capital may be lost partially or entirely due to borrower defaults or platform risks.

No Guarantee: No guarantee of capital protection or return of invested amounts.

🎯 Credit Risk

Default Risk: Borrowers may default on loan obligations despite credit assessments.

Recovery Risk: Debt collection process to be initiated and get CCJ if borrower default.

📊 Market Risk

Economic Conditions: Macroeconomic factors may adversely affect loan performance.

Interest Rate Risk: Changes in market interest rates will not impact current issued loans.

💧 Liquidity Risk

Illiquidity: Investments typically cannot be easily converted to cash.

Secondary Market: Limited secondary market liquidity may restrict exit options.

🏢 Platform Risk

Business Risk: URCASH's financial condition may affect investments.

Technology Risk: Technical failures may disrupt services and affect investments.

⚖️ Regulatory Risk

Regulatory Changes: Changes in financial regulations may impact platform operations.

Compliance Risk: Non-compliance could result in operational restrictions.

5.3 Lending Services and Credit Assessment

Advanced Credit Assessment Technology

URCASH employs sophisticated credit assessment methodologies combining traditional credit scoring with innovative alternative data analysis:

  • Multi-Bureau Credit Checks: Integration with major credit reference agencies
  • Open Banking Data: Real-time financial behavior analysis
  • Alternative Credit Scoring: Social media, transaction patterns, and behavioral data
  • AI-Driven Risk Models: Machine learning algorithms for predictive risk assessment
  • Income Verification: Employment verification and income stability analysis
  • Debt-to-Income Analysis: Comprehensive affordability assessment
👤

Personal Loans

Unsecured personal lending for various purposes with competitive rates

🏢

Business Lending

Commercial and SME lending solutions with flexible terms

🏠

Asset-Backed Lending

Secured lending products with collateral-based risk assessment

⏱️

Short-Term Finance

Quick access funding with rapid approval processes

🔄

Refinancing

Debt consolidation and refinancing solutions

🌱

Green Finance

Sustainable and environmental impact lending products

5.4 Investment and Lending Limits by Jurisdiction

Jurisdiction Individual Lender Limit Total Platform Exposure Borrower Limits
UK Subject to FCA consumer protection limits and high-net-worth exemptions No statutory limits for professional investors Consumer Credit Act restrictions apply
India (RBI Guidelines) ₹50,000 per borrower across all P2P platforms ₹10,00,000 total borrowing limit witout asset declaration ₹50,00,000 total borrowing limit with asset declaration
US State-specific limits and accredited investor exemptions Federal securities law investment limits State usury law and lending limit compliance
EU National consumer protection limits apply MiFID II professional investor exemptions National consumer credit regulations

6. FEES AND CHARGES

URCASH operates on a transparent fee structure designed to provide fair value to all platform users while ensuring sustainable platform operations and continued service excellence.

6.1 Platform Fee Structure

Core Platform Fees

Total Platform Fee: 2% on all facilitated transactions, split equally between borrowers and lenders to ensure fair cost distribution.

Fee Category Rate Charged To When Applied
Borrower Origination Fee 1% of loan amount Borrower At loan origination
Lender Origination Fee 1% of loan amount Lender At loan disbusment
Account Maintenance Free All Users Ongoing

6.2 Multi-Currency Support and Foreign Exchange

GBP (British Pound) Primary currency for UK operations with direct bank integration
USD (US Dollar) US operations and international transaction facilitation
EUR (Euro) European operations with SEPA integration
INR (Indian Rupee) India operations with UPI and RTGS integration

Foreign Exchange Services

  • Competitive FX Rates: Real-time market rates with transparent markup disclosure
  • Currency Hedging: Risk management options for large international transactions
  • Multi-Currency Accounts: Hold and transact in multiple currencies simultaneously

6.3 Payment Processing and Third-Party Fees

Third-Party Processing Fees

Additional Charges: Third-party payment processors may charge additional fees for certain transaction types. These fees are transparently disclosed before transaction completion and are not retained by URCASH.

UK Payment Methods

  • Open Banking: Free
  • Faster Payments: Free
  • BACS: Free
  • Card Payments: 2.9% + £0.30

EU Payment Methods

  • SEPA Credit Transfer: Free
  • Local Bank Transfer: Varies
  • SEPA Instant: €0.50
  • Card Payments: 2.9% + €0.30

India Payment Methods

  • UPI: Free
  • Net Banking: Free
  • NEFT: ₹5 + bank charges
  • RTGS: ₹25 + bank charges

US Payment Methods

  • ACH Transfer: Free
  • Wire Transfer: $25
  • Card Payments: 2.9% + $0.30
  • Digital Wallets: 3.4% + $0.30

7. USER CONDUCT AND PROHIBITED ACTIVITIES

URCASH maintains a secure and compliant platform environment through strict user conduct guidelines and comprehensive monitoring systems to prevent financial crime and ensure user protection.

7.1 Acceptable Use Guidelines

Legitimate Activities

Genuine investment and lending for lawful purposes

📊

Account Management

Active portfolio monitoring and responsible financial management

💬

Platform Communication

Professional interactions with support and other users

📚

Educational Content

Accessing learning resources and financial education materials

7.2 Strictly Prohibited Activities

🚫 Financial Crimes and Misconduct

Zero Tolerance Policy: URCASH maintains zero tolerance for financial crimes and will report suspected violations to appropriate authorities.

💰 Financial Misconduct

  • Money laundering or terrorist financing
  • Fraudulent financial status representation
  • Market manipulation or insider trading
  • Sanctions or export control violations
  • Tax evasion or reporting violations
  • Ponzi schemes or pyramid schemes

🔒 Platform Security Violations

  • Multiple account creation or identity fraud
  • Unauthorized access to user accounts
  • Automated trading or system manipulation
  • Security circumvention or hacking
  • Data scraping or unauthorized data extraction
  • Reverse engineering platform technology

⚖️ Legal and Regulatory Violations

  • Violation of applicable laws or regulations
  • Intellectual property rights infringement
  • Harassment or abusive behavior
  • Promotion of illegal activities
  • Privacy violations or data breaches
  • Circumventing regulatory requirements

🎯 Commercial Misuse

  • Unauthorized commercial use of platform
  • Spam or unsolicited communications
  • Competitive intelligence gathering
  • Platform data commercial exploitation
  • Brand impersonation or misrepresentation
  • Affiliate fraud or referral manipulation

7.3 Monitoring and Enforcement

Advanced Monitoring Systems

URCASH employs sophisticated monitoring and detection systems to identify and prevent prohibited activities:

  • Real-Time Transaction Monitoring: AI-powered suspicious activity detection
  • Behavioral Analytics: Pattern recognition for unusual account behavior
  • AML Compliance Screening: Continuous sanctions and PEP list monitoring
  • Fraud Detection: Multi-layered fraud prevention and detection systems
  • Regulatory Reporting: Automated suspicious activity reporting to authorities
  • User Verification: Ongoing identity verification and account monitoring

7.4 Enforcement Actions

Violation Level Enforcement Action Additional Consequences
Minor Violations Warning and educational guidance Account monitoring increase
Moderate Violations Temporary account restrictions Additional verification requirements
Serious Violations Account suspension pending investigation Transaction freezing and review
Criminal Violations Immediate account termination Law enforcement referral

8. INTELLECTUAL PROPERTY RIGHTS

URCASH respects and vigorously protects intellectual property rights while fostering innovation in financial technology. Our comprehensive IP framework ensures proper attribution, protection, and licensing of all intellectual assets.

8.1 URCASH Intellectual Property Portfolio

Platform Technology Proprietary software, algorithms and technical architecture
Brand Assets URCASH trademark, logos, service marks, and brand identity elements
User Interface Design Website design, mobile app interfaces, and user experience elements
Analytical Tools Credit scoring models, risk assessment algorithms, and predictive analytics
Educational Content Training materials, research publications, and educational resources
Business Processes Proprietary methodologies, operational procedures, and business models

8.2 User Content and Data Rights

Balanced Rights Framework

URCASH maintains a balanced approach to user content and data rights, ensuring user privacy while enabling platform operations and service improvements:

  • User Retention: Users retain ownership of personal content and information
  • Platform License: Limited license granted to URCASH for service delivery
  • Data Portability: Right to request data export in standard formats
  • Consent Management: Granular control over data processing consent

User Grant to URCASH

  • Limited license for platform operations
  • Right to process data for service improvement
  • Permission for anonymized data research
  • Marketing use with explicit consent

User Rights Protection

  • Ownership retention of personal content
  • Data export and portability rights
  • Consent withdrawal capabilities
  • Content deletion rights

8.3 Third-Party Intellectual Property

Respect for Third-Party Rights

URCASH respects all third-party intellectual property rights and maintains proper licensing arrangements for all third-party technologies, content, and services integrated into our platform.

8.4 IP Violation Reporting

IP Violation Reports

Email: ip@urcash.co.uk

Response Time: 48 hours acknowledgment

Investigation Period: 14 business days

Required Information

  • Detailed description of infringement
  • Evidence of ownership rights
  • Contact information
  • Good faith statement

9. DATA PROTECTION AND PRIVACY

URCASH is committed to the highest standards of data protection and privacy, implementing comprehensive measures to safeguard user information across all jurisdictions where we operate.

Comprehensive Privacy Framework

All personal data processing is governed by our detailed Privacy Policy, which forms an integral part of these Terms of Service. Our privacy framework encompasses:

  • Lawful Processing: All data processing based on valid legal grounds
  • Transparency: Clear communication about data use and processing
  • User Control: Granular privacy controls and consent management
  • Data Minimization: Collection limited to necessary information only
  • Security Excellence: Industry-leading security measures and protocols

9.1 Data Processing Principles

⚖️

Lawful Basis

All processing based on legitimate legal grounds with clear justification

🎯

Purpose Limitation

Data used only for specified, legitimate business purposes

📉

Data Minimization

Collection limited to necessary and proportionate information

Accuracy

Maintaining accurate and up-to-date personal information

🛡️

Security

Robust technical and organizational security measures

📋

Accountability

Demonstrable compliance with data protection requirements

9.2 Cross-Border Data Transfers

UK Data Transfers

  • Adequacy decisions compliance
  • International Data Transfer Agreements (IDTAs)
  • Standard Contractual Clauses (SCCs)
  • Binding Corporate Rules (BCRs)

EU Data Transfers

  • European Commission adequacy decisions
  • Standard Contractual Clauses (SCCs)
  • Binding Corporate Rules (BCRs)
  • Derogations for specific situations

India Data Transfers

  • DPDPA 2023 compliance framework
  • Government-notified safe countries
  • Contractual data protection safeguards
  • Explicit consent mechanisms

US Data Transfers

  • Privacy Shield Framework compliance
  • State privacy law requirements
  • Contractual safeguards and agreements
  • CCPA/CPRA transfer restrictions

9.3 User Privacy Rights

Comprehensive Rights Framework

URCASH provides extensive privacy rights to all users, with specific rights varying by jurisdiction:

  • Access Rights: Request copies of personal data held
  • Rectification Rights: Correct inaccurate or incomplete information
  • Erasure Rights: Request deletion of personal data (where legally permissible)
  • Portability Rights: Transfer data to other service providers
  • Objection Rights: Object to certain types of data processing
  • Restriction Rights: Limit processing in specific circumstances

10. REGULATORY COMPLIANCE AND REPORTING

URCASH maintains comprehensive regulatory compliance programs across all operating jurisdictions, ensuring adherence to evolving financial services regulations and consumer protection standards.

10.1 Anti-Money Laundering (AML) Framework

🇬🇧 UK/EU AML Requirements

  • Customer Due Diligence: Comprehensive identity verification
  • Enhanced Due Diligence: High-risk customer assessment
  • Ongoing Monitoring: Transaction pattern analysis
  • Suspicious Activity Reporting: FCA/FIU notifications
  • Record Keeping: 7-year transaction history retention
  • Training Programs: Staff AML awareness and compliance

🇮🇳 India PMLA Compliance

  • KYC Verification: Aadhaar and PAN-based identity checks
  • Beneficial Ownership: Ultimate ownership identification
  • Transaction Monitoring: Automated suspicious transaction detection
  • FIU-IND Reporting: Suspicious Transaction Report (STR) filing
  • Correspondent Banking: Enhanced due diligence procedures

🇺🇸 US BSA Compliance

  • Customer Identification Program: CIP verification requirements
  • Suspicious Activity Reporting: FinCEN SAR filing
  • Currency Transaction Reports: Large transaction reporting
  • Foreign Account Reporting: FBAR and FATCA compliance
  • Sanctions Screening: OFAC list monitoring
  • Risk Assessment: Customer and product risk evaluation

10.2 Consumer Protection Measures

Multi-Jurisdictional Consumer Protection

URCASH implements comprehensive consumer protection measures that exceed minimum regulatory requirements:

  • Clear Disclosure: Transparent fee and risk communication
  • Fair Treatment: Treating customers fairly principles
  • Vulnerable Customer Support: Enhanced protection for vulnerable users
  • Complaints Handling: Robust grievance redressal mechanisms
  • Financial Education: Comprehensive learning resources
  • Regular Reviews: Ongoing policy and procedure updates

🇬🇧 UK Consumer Protection

FCA Treating Customers Fairly (TCF), Consumer Duty obligations, Vulnerable customer identification

Financial Ombudsman Service

🇪🇺 EU Consumer Rights

Consumer Rights Directive, Unfair Contract Terms Directive, Distance Marketing compliance

National ADR Mechanisms

🇮🇳 India Consumer Protection

RBI consumer protection guidelines, Fair practice codes, Interest rate transparency

RBI Ombudsman Scheme

🇺🇸 US Consumer Protection

CFPB regulations, TILA compliance, FCRA adherence, EFTA requirements

CFPB Complaint Portal

10.3 Regulatory Reporting and Transparency

Comprehensive Reporting Framework

URCASH maintains transparent reporting to regulatory authorities and stakeholders:

  • Regular Regulatory Returns: Periodic financial and operational reporting
  • Incident Reporting: Immediate notification of significant events
  • Consumer Metrics: Customer outcome and satisfaction reporting
  • Risk Reporting: Regular risk assessment and mitigation updates
  • Audit Cooperation: Full cooperation with regulatory examinations
  • Public Disclosures: Transparent communication to stakeholders

11. RISK WARNINGS AND DISCLAIMERS

URCASH is committed to ensuring all users fully understand the risks associated with peer-to-peer lending and investment activities. This section provides comprehensive risk disclosure as required by financial services regulations.

11.1 General Investment Risk Warnings

⚠️ CRITICAL RISK WARNING

Your capital is at risk and you may lose some or all of your investment. Past performance is not a guarantee of future results. P2P investments are typically illiquid and may not be suitable for all investors.

💸 Capital Risk

Principal Loss: Investment capital may be lost partially or entirely

No Capital Guarantee: No protection of invested amounts

Variable Returns: Returns may be lower than expected or negative

👤 Credit Risk

Borrower Default: Risk of borrower failing to repay loans

Recovery Risk: Limited ability to recover funds from defaults

Credit Assessment Limitations: Imperfect predictive models

📊 Market Risk

Economic Conditions: Macroeconomic factors affecting performance

Interest Rate Changes: Impact on investment attractiveness

Inflation Risk: Erosion of real returns over time

💧 Liquidity Risk

Illiquid Investments: Difficulty in accessing invested funds

Secondary Market Limitations: Limited trading opportunities

Lock-up Periods: Fixed investment terms with early exit penalties

🏢 Platform Risk

Business Continuity: Risk of platform business failure

Operational Risk: Technology failures or operational disruptions

Regulatory Risk: Changes in regulatory environment

🌐 Technology Risk

Cyber Security: Risk of data breaches or cyber attacks

System Failures: Potential technology platform outages

Data Loss: Risk of transaction or account data loss

11.2 Jurisdiction-Specific Risk Disclosures

UK-Specific Risk Disclosures

  • FSCS Protection: Investments are NOT covered by the Financial Services Compensation Scheme
  • Collective Investment: Not regulated as collective investment schemes
  • FCA Authorization: Platform currently operating under Regulatory Sandbox
  • Tax Implications: Income tax on interest, potential capital gains tax
  • Consumer Credit: Subject to Consumer Credit Act regulations

EU-Specific Risk Disclosures

  • Investor Protection: Limited investor compensation scheme coverage
  • MiFID II Classification: Complex financial instruments with higher risks
  • Cross-Border Risks: Currency and jurisdictional risks
  • Tax Implications: Variable tax treatment across member states
  • Regulatory Differences: Varying national implementations

India-Specific Risk Disclosures

  • DICGC Protection: NOT insured by Deposit Insurance and Credit Guarantee Corporation
  • RBI Regulations: Subject to evolving P2P lending guidelines
  • Investment Limits: Regulatory caps on lending and borrowing amounts
  • Tax Implications: TDS on interest income, income tax applicability
  • Economic Risks: Currency fluctuation and economic instability risks

US-Specific Risk Disclosures

  • FDIC Insurance: NOT FDIC insured and not guaranteed by government
  • Securities Regulations: Securities may be illiquid with holding restrictions
  • State Variations: Different state laws and consumer protections
  • Tax Implications: Federal and state tax obligations
  • Accredited Investor: Some products limited to accredited investors

11.3 Technology and Operational Risk Disclaimers

Service Availability and Data Accuracy

  • Uptime: Platform availability not guaranteed 24/7, maintenance may cause interruptions
  • Data Accuracy: Information provided on "as-is" basis, users responsible for verification
  • Third-Party Integration: External data sources may contain errors or delays
  • Force Majeure: Service disruptions due to circumstances beyond our control

12. LIABILITY AND INDEMNIFICATION

This section outlines the allocation of liability and indemnification obligations between URCASH and users, ensuring fair and legally compliant risk distribution while protecting both parties' legitimate interests.

12.1 Limitation of URCASH Liability

⚖️ Liability Limitations

Important: URCASH's liability is limited as set out below, except where prohibited by applicable consumer protection laws or where liability cannot legally be excluded or limited.

💰 Financial Liability Limits

  • Monetary Cap: Limited to platform fees paid in 12 months preceding claim
  • Investment Losses: No liability for losses due to borrower default
  • Market Losses: No liability for market-related investment losses
  • Opportunity Costs: No liability for lost profits or opportunities

🚫 Excluded Damages

  • Indirect Damages: No liability for consequential losses
  • Special Damages: Exclusion of punitive or exemplary damages
  • Business Interruption: No liability for business disruption costs
  • Reputation: No liability for reputational damage

🔧 Service Provider Limitations

  • Third-Party Failures: No liability for external service failures
  • Payment Processors: Issues with external payment systems
  • Credit Agencies: Third-party data accuracy limitations
  • Technology Providers: External technology service disruptions

⚡ Force Majeure

  • Natural Disasters: Events beyond reasonable control
  • Government Actions: Regulatory or governmental interventions
  • Cyber Attacks: Malicious external cyber security incidents
  • Pandemic: Public health emergencies and responses

12.2 Exceptions to Liability Limitations

🚨 Non-Excludable Liability

Legal Restrictions: The following types of liability cannot be excluded or limited under applicable law:

  • Fraud or Misconduct: Deliberate fraud or willful misconduct by URCASH
  • Death or Injury: Death or personal injury caused by negligence
  • Consumer Rights: Statutory consumer rights that cannot be waived
  • Regulatory Breaches: Direct losses from regulatory compliance failures
  • Data Protection: Breaches of data protection laws causing proven damages

12.3 User Indemnification Obligations

User Indemnification Requirements

Users agree to indemnify and hold harmless URCASH, its directors, employees, and affiliates from claims arising from:

  • Terms Breach: User violation of these Terms or applicable laws
  • Fraudulent Conduct: User fraud, negligence, or intentional misconduct
  • Third-Party Claims: Claims related to user content or activities
  • Tax Obligations: User tax liabilities and regulatory violations
  • Prohibited Activities: Engagement in prohibited platform activities
  • IP Violations: Intellectual property infringement by user

12.4 Insurance and Risk Management

URCASH Risk Management

URCASH maintains comprehensive risk management and insurance coverage:

  • Professional Indemnity: Coverage for professional services errors
  • Cyber Security Insurance: Protection against cyber risks and data breaches
  • Directors & Officers: Management liability coverage
  • General Liability: Public and product liability insurance
  • Business Interruption: Coverage for operational disruptions
  • Employment Practices: Employment-related liability coverage

13. DISPUTE RESOLUTION

URCASH is committed to fair and efficient dispute resolution through multiple channels, providing accessible and cost-effective mechanisms for addressing user concerns and complaints.

13.1 Initial Resolution Process

📞

Step 1: Direct Contact

Contact customer service for immediate resolution

⏱️

Step 2: Acknowledgment

48-hour complaint acknowledgment and case assignment

🔍

Step 3: Investigation

14-day thorough investigation and analysis

📋

Step 4: Resolution

Written resolution with explanation and next steps

🔺

Step 5: Escalation

Senior management review if unsatisfied

🏛️

Step 6: External ADR

External dispute resolution options

13.2 Alternative Dispute Resolution (ADR)

🇬🇧 UK ADR Options

  • Financial Ombudsman Service (FOS): Free, independent dispute resolution
  • European ODR Platform: Online dispute resolution for EU consumers
  • Chartered Institute of Arbitrators: Professional mediation services
  • Consumer Rights Act: Statutory consumer protection rights

Contact: fca.org.uk/consumers/how-complain

🇪🇺 EU ADR Mechanisms

  • National Competent Authorities: Member state financial regulators
  • FIN-NET: European financial dispute resolution network
  • European Consumer Centres: Cross-border consumer assistance
  • Online Dispute Resolution: EU ODR platform for digital services

ODR Platform: consumer-redress.ec.europa.eu

🇮🇳 India Dispute Resolution

  • RBI Ombudsman Scheme: Banking and NBFC complaint mechanism
  • Consumer Protection Act: Consumer forums and commissions
  • Lok Adalat: Alternative dispute resolution courts
  • Arbitration Act: Commercial arbitration procedures

RBI Ombudsman: rbi.org.in

🇺🇸 US Dispute Resolution

  • CFPB Complaint Portal: Federal consumer financial complaints
  • American Arbitration Association: Commercial arbitration services
  • State Attorneys General: State-level consumer protection
  • Better Business Bureau: Business dispute mediation

CFPB Portal: consumerfinance.gov/complaint

13.3 Arbitration and Legal Proceedings

Binding Arbitration Framework

For disputes that cannot be resolved through internal processes or ADR mechanisms:

  • Arbitration Rules: Binding arbitration under recognized institutional rules
  • Language: Proceedings conducted in English
  • Seat of Arbitration: London, England for international disputes
  • Applicable Law: English law, subject to mandatory consumer protections
  • Arbitrator Selection: Mutual agreement or institutional appointment
  • Final and Binding: Arbitral awards enforceable in courts

13.4 Governing Law and Jurisdiction

Legal Framework

  • Primary Governing Law: Laws of England and Wales
  • Court Jurisdiction: English courts for legal proceedings
  • Consumer Protection Override: Local consumer laws take precedence where applicable
  • Regulatory Jurisdiction: Local regulatory authority jurisdiction for compliance matters
  • Class Action Waiver: Individual dispute resolution preferred (where legally permissible)

14. ACCOUNT TERMINATION AND SUSPENSION

URCASH provides clear procedures for both user-initiated and platform-initiated account termination, ensuring fair treatment and proper handling of outstanding obligations.

14.1 User-Initiated Termination

Notice Period 30-day written notice required for complete account closure
Outstanding Obligations All loans, investments, and fees must be settled before closure
Data Retention Personal data retained per regulatory requirements and Privacy Policy
Partial Termination Option to terminate specific services while maintaining core account

Account Closure Process

  1. Closure Request: Submit formal written request via secure portal or email
  2. Identity Verification: Confirm identity and account ownership
  3. Outstanding Review: Complete assessment of all outstanding obligations
  4. Settlement Period: Allow time for final transactions and settlements
  5. Data Export: Provide final account statements and transaction history
  6. Account Deactivation: Formal account closure and confirmation

14.2 URCASH-Initiated Termination

⚠️ Grounds for Account Termination

URCASH reserves the right to suspend or terminate accounts for the following reasons:

🚫 Material Breach

  • Violation of Terms of Service
  • Fraudulent or misleading information
  • Prohibited activities engagement
  • Failure to meet eligibility requirements

⚖️ Legal and Regulatory

  • AML/KYC compliance failures
  • Sanctions list inclusion
  • Court orders or legal requirements
  • Regulatory authority instructions

🔒 Security and Risk

  • Account security compromise
  • Unusual or suspicious activity
  • Risk management decisions
  • Platform security threats

📊 Operational

  • Extended account inactivity (24+ months)
  • Failure to respond to verification requests
  • Business model changes
  • Service discontinuation

14.3 Effects of Termination

Post-Termination Obligations and Rights

Upon account termination, the following provisions remain in effect:

  • Existing Investments: Continue until natural maturity or early redemption
  • Outstanding Loans: Remain subject to original loan terms and conditions
  • Platform Fees: All accrued fees remain due and payable
  • Confidentiality: Confidentiality obligations survive termination indefinitely
  • Dispute Resolution: Dispute resolution procedures remain available
  • Data Processing: Continued processing for legal and regulatory compliance

15. BUSINESS CONTINUITY AND FORCE MAJEURE

URCASH maintains comprehensive business continuity planning to ensure service continuity and user protection during unexpected events or circumstances beyond our reasonable control.

15.1 Business Continuity Framework

🔄

Backup Systems

Redundant systems and disaster recovery procedures

🔀

Alternative Services

Alternative service provision arrangements during disruptions

📢

Communication

Clear customer communication protocols during emergencies

📋

Regulatory Compliance

Maintained regulatory reporting and compliance during crises

🏥

Crisis Management

Dedicated crisis management team and procedures

🔍

Regular Testing

Periodic testing and updating of continuity plans

15.2 Force Majeure Events

🌍 Natural Disasters

  • Earthquakes, floods, hurricanes, wildfires
  • Extreme weather conditions
  • Geological events and natural catastrophes
  • Environmental emergencies

🏛️ Government Actions

  • Emergency legislation or regulations
  • Government sanctions or restrictions
  • Currency controls or capital restrictions
  • Public health measures and lockdowns

🛡️ Security and Cyber Events

  • Large-scale cyber attacks
  • Critical infrastructure failures
  • Internet or telecommunications disruptions
  • Third-party security breaches affecting operations

🏥 Public Health Emergencies

  • Pandemic or epidemic diseases
  • Public health quarantine measures
  • Healthcare system emergencies
  • Travel restrictions and border closures

15.3 Force Majeure Effects and Response

Response to Force Majeure Events

In the event of force majeure circumstances, URCASH will:

  • Service Continuity: Make reasonable efforts to maintain essential services
  • User Communication: Provide regular updates on service status and expected resolution
  • Alternative Arrangements: Implement alternative service delivery methods where possible
  • Liability Suspension: Suspend liability for service interruptions due to force majeure
  • Timeline Extensions: Extend deadlines and time limits as necessary
  • Regulatory Coordination: Coordinate with regulatory authorities as required

15.4 User Obligations During Disruptions

User Responsibilities

During business continuity events or force majeure situations, users are expected to:

  • Stay Informed: Monitor official URCASH communications for updates
  • Alternative Access: Use alternative access methods when available
  • Patience and Understanding: Allow additional time for service restoration
  • Contact Information: Ensure contact details are current for emergency communication
  • Security Vigilance: Maintain heightened security awareness during disruptions

16. REGULATORY CHANGES AND UPDATES

URCASH operates in a dynamic regulatory environment and maintains robust procedures to adapt to regulatory changes while ensuring continued compliance and service excellence.

16.1 Regulatory Monitoring and Adaptation

Continuous Monitoring Real-time tracking of regulatory developments across all operating jurisdictions
Expert Advisory Dedicated regulatory affairs team and external legal counsel
Impact Assessment Systematic evaluation of regulatory changes on platform operations
Implementation Planning Structured approach to implementing regulatory requirements
User Communication Transparent communication of changes affecting users
Compliance Validation Regular compliance audits and validation procedures

16.2 Response to Regulatory Changes

📊

Platform Updates

Technology and process updates to maintain regulatory compliance

📧

User Notification

Advance notice of material changes affecting user rights or obligations

🔧

Service Modifications

Adaptation or modification of services as required by new regulations

🚫

Service Discontinuation

Responsible discontinuation of services if regulatory compliance impossible

16.3 Terms of Service Updates

Amendment Process and User Rights

URCASH follows a structured process for updating these Terms of Service:

  • Advance Notice: Minimum 30-day notice for material changes
  • Email Notification: Direct notification to all active users via registered email
  • Website Publication: Updated terms published on website with effective date
  • Explanation of Changes: Clear explanation of modifications and their impact
  • User Options: Right to terminate account if changes are unacceptable
  • Continued Use Acceptance: Continued platform use constitutes acceptance of changes

⚠️ Important User Rights

Right to Terminate: If you do not agree to any material changes to these Terms, you have the right to terminate your account without penalty during the notice period. Termination requests must be submitted within 30 days of notification.

17. CONSUMER CREDIT AND LENDING REGULATIONS

URCASH operates under comprehensive consumer credit regulations across all jurisdictions, ensuring robust borrower protection and responsible lending practices.

17.1 UK Consumer Credit Regulations

📋 Consumer Credit Act 1974

  • Cooling-off Period: 14-day withdrawal right from credit agreements
  • Credit Terms Disclosure: Clear and prominent disclosure requirements
  • Early Settlement Rights: Right to settle agreements early with rebate
  • Unfair Relationships: Protection from unfair credit relationships

🏛️ FCA Consumer Credit Sourcebook

  • Responsible Lending: Comprehensive affordability assessments
  • Income Verification: Robust verification of borrower income
  • Clear Communication: Transparent cost and risk communication
  • Vulnerable Customers: Enhanced protection and support mechanisms

17.2 India NBFC-P2P Regulations

RBI Master Direction Compliance Full compliance with Reserve Bank of India guidelines for P2P lending platforms
Lending and Borrowing Limits Strict adherence to prescribed individual and aggregate exposure limits
Escrow Account Management Mandatory escrow arrangements for all platform transactions
Board Oversight Requirements Independent board oversight and risk management frameworks
Customer Grievance Mechanism Comprehensive grievance redressal and resolution procedures
Technology and Data Security Robust technology infrastructure and data protection measures

17.3 US Federal and State Lending Laws

Federal Regulations

  • Truth in Lending Act (TILA): Comprehensive disclosure requirements
  • Equal Credit Opportunity Act (ECOA): Non-discrimination in lending
  • Fair Credit Reporting Act (FCRA): Credit reporting requirements
  • Electronic Fund Transfer Act (EFTA): Electronic payment protections

State Regulations

  • State Licensing: Money transmission and lending licenses
  • Interest Rate Caps: State usury law compliance
  • Consumer Protection: State consumer protection statutes
  • Debt Collection: State debt collection regulations

17.4 EU Consumer Credit Directives

European Consumer Credit Framework

  • Consumer Credit Directive: Harmonized EU consumer credit rules
  • Mortgage Credit Directive: Responsible mortgage lending standards
  • Payment Services Directive (PSD2): Strong customer authentication
  • Consumer Rights Directive: Comprehensive consumer protection
  • Unfair Commercial Practices Directive: Protection from unfair practices

18. INVESTMENT SERVICES REGULATIONS

URCASH provides investment services under comprehensive regulatory frameworks designed to protect investors and ensure market integrity across all operating jurisdictions.

18.1 UK Investment Service Regulations

Financial Services and Markets Act 2000

URCASH operates under the UK's comprehensive financial services regulatory framework:

  • Regulated Activities: Proper authorization for all regulated investment activities
  • Client Categorization: Appropriate classification of retail, professional, and eligible counterparty clients
  • Conduct Standards: High standards of business conduct and customer treatment
  • Financial Promotions: Compliance with financial promotion rules and restrictions
  • Client Money Rules: Segregation and protection of client funds

18.2 EU Investment Service Regulations

🏛️ MiFID II Compliance

  • Investor Protection: Comprehensive investor protection measures
  • Suitability Assessment: Detailed suitability and appropriateness tests
  • Product Governance: Target market identification and monitoring
  • Best Execution: Best execution obligations for client orders

📊 Transparency Requirements

  • Pre-trade Transparency: Price and volume disclosure requirements
  • Post-trade Reporting: Transaction reporting to regulatory authorities
  • Client Reporting: Regular client portfolio and performance reporting
  • Research Unbundling: Separation of research and execution costs

18.3 US Securities Regulations

Securities Act of 1933 Registration requirements, disclosure obligations, and anti-fraud provisions for securities offerings
Securities Exchange Act of 1934 Ongoing reporting, proxy regulations, and market conduct rules
Investment Advisers Act of 1940 Registration, fiduciary duties, and compliance requirements for investment advisers
Sarbanes-Oxley Act Corporate governance, internal controls, and financial reporting requirements
Dodd-Frank Act Systemic risk oversight, consumer protection, and derivatives regulation
JOBS Act Crowdfunding regulations and small business capital formation

18.4 Fiduciary Duties and Client Protection

⚖️ Fiduciary Responsibilities

Client Interest Priority: URCASH maintains the highest standards of fiduciary care, placing client interests ahead of our own in all investment-related activities and recommendations.

🛡️

Client Asset Protection

Segregation and safekeeping of client assets per regulatory requirements

🎯

Suitability Assessment

Comprehensive assessment of investment suitability and appropriateness

💡

Conflict Management

Identification, management, and disclosure of conflicts of interest

📋

Record Keeping

Comprehensive record keeping and audit trail maintenance

19. TAX CONSIDERATIONS

URCASH provides general information about potential tax implications of platform activities. Users are solely responsible for understanding and complying with their tax obligations in their respective jurisdictions.

🏛️ Important Tax Disclaimer

Professional Advice Required: This information is for general guidance only and does not constitute tax advice. Users must seek professional tax advice from qualified advisors regarding their specific circumstances and obligations.

19.1 General Tax Responsibilities

🎯

Tax Determination

Users must determine their own tax implications and obligations

📊

Income Reporting

Report all income and gains to relevant tax authorities

💰

Tax Payments

Pay all applicable taxes and penalties as required

👥

Professional Advice

Seek qualified professional tax advice for complex situations

19.2 Jurisdiction-Specific Tax Information

UK Tax Implications

Income Tax on Interest Interest from P2P lending subject to income tax at marginal rates
Personal Savings Allowance £1,000 (basic rate) or £500 (higher rate) annual allowance
Capital Gains Tax Potential CGT on disposal of loan investments
ISA Eligibility Some P2P investments may qualify for ISA treatment

EU Tax Implications

Withholding Tax Cross-border payments may be subject to withholding tax
VAT on Services Platform services may be subject to Value Added Tax
Local Income Tax Investment returns subject to local income tax rules
Double Tax Treaties Potential relief under bilateral tax treaties

India Tax Implications

TDS on Interest Tax Deducted at Source on interest payments above threshold
Income Tax on Interest Interest income taxable under "Income from Other Sources"
Capital Gains on Transfers Potential capital gains tax on loan assignment/transfer
GST on Platform Services Goods and Services Tax applicable on platform fees

US Tax Implications

Form 1099 Reporting Annual reporting of interest and dividend income
Federal and State Income Tax Interest income subject to ordinary income tax rates
Capital Gains Treatment Sale of loan investments may qualify for capital gains treatment
Alternative Minimum Tax Potential AMT implications for high-income taxpayers

19.3 Platform Tax Support Services

URCASH Tax Support

  • Annual Statements: Comprehensive annual tax reporting statements
  • Transaction History: Detailed records of all taxable transactions
  • Tax Calculation Tools: Online tools to help calculate potential tax liabilities
  • Educational Resources: Tax guidance and educational materials
  • Professional Referrals: Referrals to qualified tax professionals
  • Regulatory Reporting: Compliance with tax authority reporting requirements

20. MISCELLANEOUS PROVISIONS

These miscellaneous provisions address important legal and operational aspects of your relationship with URCASH that support the overall Terms of Service framework.

20.1 Entire Agreement

Complete Agreement

These Terms of Service, together with our Privacy Policy, Cookie Policy, and any additional service-specific agreements, constitute the complete and exclusive agreement between you and URCASH regarding your use of our platform and services.

20.2 Severability

Legal Severability

If any provision of these Terms is found to be unenforceable, invalid, or contrary to applicable law by a court of competent jurisdiction:

  • Remaining Provisions: All other provisions shall continue in full force and effect
  • Invalid Provision Replacement: Invalid provisions shall be replaced with valid provisions that achieve similar economic effects
  • Minimal Impact: The invalidity shall not affect the overall validity of these Terms

20.3 Waiver and Enforcement

No Implied Waiver URCASH's failure to enforce any right or provision does not constitute a waiver
Express Waiver Required Waivers must be explicit and in writing to be effective
No Continuing Waiver Single instances of waiver do not constitute continuing waiver
Selective Enforcement URCASH may enforce provisions selectively without waiving other rights

20.4 Assignment and Transfer

URCASH Assignment Rights

  • Unrestricted Assignment: URCASH may assign these Terms without user consent
  • Business Transfers: Assignment in connection with mergers, acquisitions, or asset sales
  • Affiliate Transfers: Assignment to affiliated companies or subsidiaries
  • User Notification: Reasonable notice of assignment to users

User Assignment Restrictions

  • Consent Required: Users cannot assign without URCASH's written consent
  • Personal Agreement: Terms are personal to the individual user
  • Non-Transferable: Account rights are non-transferable
  • Successor Obligations: Permitted successors bound by original terms

20.5 Notices and Communications

📧

Electronic Notice

Primary communication via registered email address

📱

Platform Messaging

In-platform notifications and messaging system

📮

Postal Mail

Physical mail to registered address when required

📄

Website Publication

Important notices published on website

20.6 Language and Translation

🌐 Official Language

English Version Prevails: These Terms are originally drafted in English. Any translations are provided for convenience only. In case of any inconsistency between the English version and any translation, the English version shall prevail.

20.7 Headings and Interpretation

Document Interpretation

  • Headings: Section and subsection headings are for convenience only and do not affect interpretation
  • References: References to sections include subsections unless otherwise specified
  • Plural/Singular: Words in singular include plural and vice versa where appropriate
  • Gender: References to one gender include all genders where applicable
  • Including: "Including" means "including without limitation" unless otherwise specified

21. CONTACT INFORMATION

URCASH maintains multiple channels for user communication, support, and legal correspondence. Please use the appropriate contact method for your specific needs.

21.1 Primary Contact Channels

📧 General Inquiries

Email: info@urcash.co.uk

Response Time: Within 24 hours

Business Hours: Monday-Friday, 9:00 AM - 6:00 PM GMT

📞 Phone Support

Phone: +44(0) 808 271 0446

Availability: Monday-Friday, 9:00 AM - 6:00 PM GMT

Emergency Support: Available 24/7 for critical security issues

🏢 Registered Office

Address: URCASH Financial Platform Services UK Limited

20 Wenlock Road, London, England, N1 7GU

Company Number: 16389705 (England & Wales)

🌐 Online Platforms

Main Website: www.urcash.co.uk

Beta Platform: beta.urcash.co.uk

Investor Portal: investor.excent.co.uk

Authorization Server: beta.uk.user.excent.io

21.2 Specialized Contact Services

⚖️ Legal and Compliance

🛠️ Customer Support

💰 Financial Services

🌍 Regional Correspondence

21.3 Emergency and Security Contacts

🚨 Security Emergencies

Immediate Security Issues: For suspected fraud, account compromise, or security breaches, contact us immediately:

Final Declaration

These Terms of Service are effective as of August 6, 2025, and supersede all previous versions.

By using our platform, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy.

© 2025 URCASH Financial Platform Services UK Limited. All rights reserved.