TheScreeningCompany 1. Introduction and Acceptance These Terms and Conditions (“Terms”) govern your access to and use of the website, platform, and screening-related services provided by TheScreeningCompany (the “Services”). By creating an account, submitting information, making payment, or otherwise using the Services, you confirm that you have read, understood, and agree to be legally bound by these Terms. If you do not agree, you must not use the Services. If you act on behalf of another person or entity, you warrant that you are authorised to bind them. 2. Nature of the Services TheScreeningCompany provides administrative screening facilitation, including document collection, processing, and generation of screening reports (“Screening Reports”). The Services: do not constitute legal, financial, or professional advice; do not amount to certification, approval, or verification; do not guarantee any outcome with any third party (“Provider”). All decisions (e.g. tenancy, employment, lending) are made solely by the relevant Provider. TheScreeningCompany has no control over, and accepts no responsibility for, such decisions. 3. Applicant Obligations You confirm that: all information and documents provided are accurate, complete, lawful, and not misleading; you are authorised to submit all materials; you will provide requested information within required timeframes. You remain solely responsible for the content you submit and any consequences arising from it. TheScreeningCompany may suspend or terminate access where it suspects fraud, misuse, or breach of these Terms. 4. Accounts and Eligibility You must be at least 18 years old and legally capable of entering into a contract. You are responsible for maintaining the confidentiality and security of your account and all activity under it. 5. Fees and Payments All Services are subject to fees as stated at the time of purchase. Fees are deemed earned upon commencement of the screening process and are non-refundable, except where required by law. This applies regardless of: completion status; outcome; Provider decisions; or your decision to discontinue. Failure to provide required information may result in closure of your file without refund. 6. Screening Reports Screening Reports: are based solely on Applicant-provided information; represent a snapshot at the time of issue; are informational only and not legally binding. TheScreeningCompany does not guarantee acceptance by any Provider or any specific outcome. 7. Use of Services and Restrictions You may use the Services only for lawful personal purposes. You must not copy, reverse engineer, exploit, or misuse any part of the platform, reports, or underlying systems. All intellectual property remains the property of TheScreeningCompany or its licensors. 8. Data and Privacy Use of the Services involves processing personal data. By using the Services, you consent to such processing in accordance with the Privacy Policy. You are responsible for ensuring lawful submission of any personal data, including third-party data. 9. Suspension and Termination TheScreeningCompany may suspend or terminate access at any time where reasonably necessary, including for breach, fraud risk, or misuse. Termination does not affect accrued rights, fees, or obligations intended to survive. 10. Chargebacks and Payment Disputes You agree not to initiate unjustified payment disputes or chargebacks. Where you do so in breach of these Terms, TheScreeningCompany may: suspend services; recover associated costs; claim a reasonable fixed compensation of up to £1,500 (or equivalent), where permitted by law. 11. Disclaimers The Services are provided “as is” and “as available”. To the fullest extent permitted by law, TheScreeningCompany makes no warranties regarding availability, accuracy, completeness, or suitability for any purpose. TheScreeningCompany is not responsible for failures caused by third parties or events beyond its control. 12. Limitation of Liability To the fullest extent permitted by law, TheScreeningCompany shall not be liable for: indirect or consequential losses; Provider decisions; inaccuracies in Applicant data; third-party actions or delays. Total liability shall not exceed the greater of £20 or the amount paid by you for the relevant Service. Nothing excludes liability where unlawful to do so. 13. Indemnity You agree to indemnify and hold harmless TheScreeningCompany from any claims, losses, or costs arising from: your breach of these Terms; false or unlawful submissions; misuse of the Services; disputes or claims involving third parties. 14. Communications and Complaints You agree to receive communications electronically. TheScreeningCompany may decline abusive or unfounded complaints, subject to applicable law. 15. Governing Law and Disputes These Terms are governed by the laws of Switzerland, unless mandatory law provides otherwise. Disputes shall be subject to the jurisdiction of the courts of Geneva, Switzerland. Before formal proceedings, parties shall attempt to resolve disputes in good faith within 30 days. Where permitted, disputes shall be administered through recognised international dispute mechanisms, including those of the World Intellectual Property Organization (WIPO), with costs borne by the Applicant unless otherwise required by law. 16. General These Terms constitute the entire agreement. If any provision is invalid, the remainder remains enforceable. TheScreeningCompany may assign its rights without restriction. Failure to enforce any right does not constitute a waiver. Provisions intended to survive termination shall remain in effect.

TheScreeningCompany 1. Introduction and Acceptance These Payment Terms of Service (“Payment Terms”) govern all payments, charges, billing arrangements, refunds, non-refundability provisions, chargebacks, recovery rights, and related financial matters connected with your use of the website, platform, applications, and screening-related services provided by TheScreeningCompany (the “Services”). By creating an account, starting a screening process, selecting a paid service, submitting payment details, authorising a payment, or otherwise using any paid part of the Services, you confirm that you have read, understood, and agree to be legally bound by these Payment Terms, together with the general Terms and Conditions, Privacy Policy, and any service-specific terms presented to you. If you do not agree, you must not make any payment or use any paid Service. 2. Scope of Paid Services TheScreeningCompany may charge fees for screening services, document handling, premium support, optional verification, expedited processing, administrative steps, add-ons, subscriptions where offered, and related paid features. TheScreeningCompany may change, introduce, remove, rename, repackage, or reprice any paid service or fee at any time, subject to applicable law. Any reference to possible future services or features does not create any entitlement unless expressly included at the point of purchase. 3. Payment-First Model Unless expressly stated otherwise, the Services operate on a payment-first basis. This means the applicable fee must be paid in full before access is granted to the relevant screening process or paid feature. You acknowledge that, once a paid service is initiated, TheScreeningCompany immediately allocates administrative, technical, fraud-prevention, compliance, support, and processing resources. Accordingly, to the fullest extent permitted by law, fees are deemed earned as soon as the relevant paid service or processing step begins, even if you do not complete the process or later abandon it. 4. Fees and Payment Obligations All fees are payable in the currency displayed at checkout or otherwise specified by TheScreeningCompany. You are responsible for all fees, taxes, duties, bank charges, processor charges, foreign exchange costs, and similar amounts arising from your transaction, unless stated otherwise. TheScreeningCompany may verify payment details, place temporary authorisations, delay service activation pending clearance, reject suspicious or high-risk transactions, or require an alternative payment method. If a payment method fails, is declined, expires, is reversed, or cannot be processed, TheScreeningCompany may suspend or cancel the relevant service without liability. You remain responsible for all unpaid amounts and related charges. 5. Non-Refundability All payments are final and strictly non-refundable, except where mandatory law requires otherwise. This applies regardless of: whether you complete the screening process; whether you provide all requested documents or information; whether documents are accepted, rejected, incomplete, inconsistent, or unclear; whether a Screening Report is issued; whether the report is favourable, unfavourable, neutral, limited, or inconclusive; whether any Provider accepts, rejects, ignores, delays, questions, or refuses to rely on the report; whether your expectations are met; or whether you later decide not to proceed. Payment is for access to TheScreeningCompany’s screening, handling, administrative, technical, and reporting process, and not for any guaranteed result, approval, tenancy, employment, financing, or other outcome. Dissatisfaction with a Provider’s decision, the contents of a Screening Report, or the commercial value of the Services does not create any right to a refund. Where TheScreeningCompany states that a payment has “no expiry date”, this means only that the payment itself is not automatically cancelled under internal policy. It does not oblige TheScreeningCompany to keep any file, process, feature, or service open indefinitely. 6. No Refund for Non-Completion or Applicant Error No refund shall be due if you fail to complete the process, fail to submit required information in time, submit inaccurate or inconsistent information, upload unsuitable documents, or otherwise prevent or delay completion of the service. You remain solely responsible for ensuring that all information and documents submitted are accurate, complete, current, lawful, and not misleading. TheScreeningCompany is not responsible for any loss arising from your failure to read these Payment Terms, understand the service, or comply with submission requirements. 7. Discretionary Relief Where not prohibited by law, TheScreeningCompany may, in exceptional circumstances and entirely at its sole discretion, offer a goodwill credit, partial refund, replacement process, coupon, or account adjustment. Any such relief is voluntary, does not amount to an admission of liability, creates no precedent, and gives no ongoing or future right. TheScreeningCompany may attach reasonable conditions to any such relief. 8. Chargebacks and Payment Disputes You agree not to initiate or support any unjustified chargeback, payment reversal, refund claim, retrieval request, or similar payment dispute, except where you genuinely and reasonably believe the payment was unauthorised or processed in error. If you do so, TheScreeningCompany may: suspend or terminate your account; suspend any active screening; refuse to issue or release any Screening Report; refuse future service; block associated payment methods; and recover all unpaid, reversed, or disputed sums together with related costs. Where a dispute is unfounded, abusive, dishonest, or otherwise brought in breach of these Payment Terms, TheScreeningCompany may recover all reasonable resulting losses, including processor fees, administrative costs, legal costs, recovery costs, bank charges, and reversed principal amounts. Without prejudice to its right to prove higher actual loss where lawful, TheScreeningCompany may also claim a fixed administrative contribution of up to EUR 990 per case, and where applicable under the governing legal documents or in cases of abusive dispute conduct, up to EUR 1,500, GBP 1,500, or USD 1,500 per dispute event, to the extent lawful and enforceable. 9. Recovery and Enforcement If any amount remains unpaid, or any payment is reversed, cancelled, clawed back, or only partly recovered, TheScreeningCompany may recover the amount by any lawful means. To the extent permitted by law and payment network rules, you authorise TheScreeningCompany to reattempt collection using the same or any updated payment method linked to your account for sums properly due. TheScreeningCompany may send reminders, invoices, payment demands, and default notices electronically. If collection is referred to a third party, you remain liable, to the extent permitted by law, for reasonable recovery and enforcement costs. 10. Payment Review Requests If you believe you are entitled to relief despite the non-refundable nature of the Services, you must first contact TheScreeningCompany through the designated contact method and submit a payment review request with sufficient supporting information. TheScreeningCompany may request additional information before considering the matter. A review request does not create any obligation to refund and does not suspend your obligations under these Payment Terms. 11. Payment Method Authorisation By providing a payment method, you confirm that: you are authorised to use it; the payment details are accurate and complete; the payment method is valid; and the transaction does not breach any applicable law or contractual restriction binding on you. You authorise TheScreeningCompany and its payment providers to charge your selected payment method for all sums lawfully due. TheScreeningCompany may use third-party processors, gateways, anti-fraud tools, and verification partners for payment handling and risk management. Use of those third parties may also be subject to their own terms and privacy policies. 12. Taxes, Currency, and Third-Party Processing Unless expressly stated otherwise, displayed prices may exclude taxes or similar mandatory charges. Where currency conversion applies, exchange rates and conversion fees may be determined by your bank, card issuer, wallet provider, or payment processor. TheScreeningCompany accepts no responsibility for resulting differences or additional charges. TheScreeningCompany is not responsible for delays, rejections, reversals, outages, or restrictions caused by banks, payment processors, wallet providers, anti-fraud systems, or other third parties beyond its reasonable control. TheScreeningCompany may delay or withhold commencement or continuation of the paid service until payment has been successfully authorised, cleared, and, where required, settled. 13. Fraud Prevention TheScreeningCompany may use automated and manual fraud checks, risk scoring, device analysis, transaction monitoring, payment method validation, and related controls. It may reject, void, suspend, or flag any payment or order reasonably suspected to be fraudulent, unauthorised, unlawful, abusive, or high-risk. It may also require proof of identity, proof of payment method ownership, enhanced verification, or alternative payment arrangements before accepting or continuing a transaction. 14. Relationship with Other Terms These Payment Terms form part of the wider contractual framework governing the Services and do not limit any other right, disclaimer, restriction, or remedy available to TheScreeningCompany under the general Terms and Conditions, Privacy Policy, applicable law, or any other binding document. In particular, you remain solely responsible for the truthfulness, completeness, and legality of all submitted information, and TheScreeningCompany does not guarantee any Provider decision or other outcome. 15. Applicant Acknowledgements By making payment, you confirm that: you have read these Payment Terms carefully; you understand that payments are final and non-refundable except where mandatory law requires otherwise; you understand that TheScreeningCompany provides a screening and reporting service only and does not control Provider decisions; you are not relying on any statement not expressly set out in the governing legal documents; and you accept full responsibility for proceeding with the purchase. 16. Limitation of Liability To the fullest extent permitted by law, TheScreeningCompany shall not be liable for any indirect, incidental, special, punitive, or consequential loss arising from or connected with payments, billing issues, processor failures, delays, rejected payments, reversed payments, or enforcement of these Payment Terms. This includes, without limitation, bank delays, foreign exchange losses, card issuer restrictions, digital wallet limitations, third-party payment fraud outside TheScreeningCompany’s reasonable control, rejected transactions, and Provider decisions made after payment. Any overall liability remains subject to the wider limitation of liability provisions set out in the governing Terms and Conditions. 17. Governing Law and Payment Disputes Unless mandatory law requires otherwise, these Payment Terms are governed by the laws of Switzerland. Any payment-related complaint or dispute must first be raised directly with TheScreeningCompany through the designated contact channel. Where formal proceedings are initiated by the Applicant, and where lawful and applicable under the governing legal framework adopted by TheScreeningCompany, the matter may be submitted through the World Intellectual Property Organization (WIPO) in accordance with its applicable rules and procedures. To the extent permitted by law, the Applicant shall bear all filing fees, administrative fees, procedural costs, and related expenses. If a claim is found to be invalid, inadmissible, unfounded, abusive, or unsubstantiated, the Applicant shall remain liable for all resulting costs, including their own costs, WIPO costs, and TheScreeningCompany’s reasonable legal and administrative costs. 18. Changes to These Payment Terms TheScreeningCompany may amend these Payment Terms at any time for legal, regulatory, security, anti-fraud, technical, operational, commercial, or business reasons. Revised Payment Terms take effect on the date specified by TheScreeningCompany, unless mandatory law requires a longer notice period. Your continued use of the Services after that date constitutes acceptance of the revised Payment Terms. 19. General These Payment Terms, together with the wider legal documents governing the Services, constitute the entire agreement in relation to payment matters. You acknowledge that you have not relied on any statement not expressly set out in those documents. If any provision is invalid or unenforceable, the remainder shall remain in full force. Any provision intended to survive termination, suspension, non-use, or account closure shall continue in effect, including provisions on non-refundability, recovery, disputes, liability, and governing law.

TheScreeningCompany 1. Introduction and Acceptance These Additional (Premium Service) Terms of Service (“Premium Terms”) govern your purchase, access to, and use of any enhanced, optional, premium, recurring, subscription-based, promotional, or otherwise non-standard screening-related service provided by TheScreeningCompany (the “Premium Services”). These Premium Terms supplement and form part of the wider contractual framework governing the Services, including the general Terms and Conditions, Privacy Policy, payment terms, checkout disclosures, workflow disclosures, and any feature-specific notices. If there is any inconsistency, these Premium Terms apply specifically to Premium Services, unless mandatory law requires otherwise. By selecting, purchasing, activating, subscribing to, or otherwise using any Premium Service, you confirm that you have read, understood, and agree to be legally bound by these Premium Terms. If you do not agree, you must not use any Premium Service. 2. Scope of Premium Services Premium Services are optional services offered in addition to, or as an enhancement of, the standard screening service. They may include enhanced screening layers, extended report availability, subscription access, premium workflow options, additional verification modules, expedited handling, premium support, promotional packages, and similar non-standard service features. TheScreeningCompany may decide, at its discretion, which Premium Services are offered, to whom, on what terms, for how long, and in which jurisdictions, platforms, workflows, or promotional contexts. Reference to a Premium Service does not oblige TheScreeningCompany to keep it available indefinitely or to provide any future upgrade, continued availability, or expanded functionality. 3. Applicant Warranties and Responsibilities By using any Premium Service, you represent, warrant, and undertake on an ongoing basis that: you are at least 18 years old and legally capable of entering into a binding contract; all information, data, declarations, and documents submitted by you are true, accurate, complete, current, lawful, and not misleading; you are lawfully entitled to submit all materials provided through the Services; any payment method used by you is valid and authorised; and your use of the Services does not breach any applicable law, third-party right, court order, or contractual obligation. You accept sole responsibility for the consequences of any inaccurate, incomplete, false, forged, manipulated, outdated, unlawful, or misleading submission. TheScreeningCompany may suspend, reject, delay, restrict, or terminate access where such issues arise or are reasonably suspected. 4. Nature of the Premium Services TheScreeningCompany provides administrative and technical screening-related services only. It does not provide legal, financial, tax, compliance, or other professional advice. It does not issue any legally binding, certified, official, or guaranteed determination. Any screening output is based on Applicant-submitted information, system workflows, available verification signals, and internal operational processes. TheScreeningCompany is not the decision-maker and does not approve, reject, certify, endorse, or guarantee any Applicant. All final decisions remain solely with the relevant Provider or third party. TheScreeningCompany does not guarantee that any Screening Report or Premium Service output will be accepted by a Provider, satisfy a Provider’s requirements, or result in any favourable tenancy, employment, lending, contractual, or commercial outcome. 5. Payment for Premium Services Access to Premium Services may require payment of a one-off fee, recurring subscription fee, promotional or trial amount, verification amount, processing charge, or other fee disclosed at checkout or within the relevant workflow. To the fullest extent permitted by law, all Premium Service fees are deemed earned upon activation, initiation of the relevant service, commencement of the subscription term, or start of the relevant processing or verification step. Except where mandatory law requires otherwise, all Premium Service payments are final and strictly non-refundable, regardless of: whether you complete the screening process; whether a report is generated; whether you stop using the service; whether the outcome is unfavourable, neutral, limited, or inconclusive; whether a Provider rejects or ignores the output; whether you no longer wish to continue; or whether you consider the service less useful than expected. Payment is made in return for allocation of technical resources, screening infrastructure, verification workflows, processor integrations, fraud controls, support, compliance steps, and administrative handling, and not for any guaranteed result. Where a Premium Service includes a nominal verification payment, such as EUR 0.01, USD 0.01, or equivalent, that amount may be used as a technical verification, payment validation, eligibility, or processor-routing step. The pricing, scope, duration, renewal terms, and key conditions shown at checkout or on the relevant offer page shall apply to the specific Premium Service purchased, together with these Premium Terms. 6. Subscriptions and Automatic Renewal Where a Premium Service is provided on a subscription or recurring basis, it shall renew automatically for successive periods unless cancelled before the end of the then-current billing term, except where mandatory law requires otherwise. You authorise TheScreeningCompany and its payment providers to charge your payment method automatically for all recurring subscription fees and related amounts due on renewal. Renewal charges will be applied at the rate in force at the time of renewal unless a different rate has been expressly agreed or mandatory law requires further notice or consent. You are solely responsible for maintaining a valid payment method, monitoring renewal dates, and cancelling in time if you do not wish the subscription to continue. If a payment cannot be processed, TheScreeningCompany may suspend, restrict, terminate, downgrade, or withhold the Premium Service, without prejudice to its right to recover any unpaid amount. Any trial, introductory, nominal-fee, or promotional subscription may convert into a paid recurring subscription if that conversion has been disclosed at checkout and you do not cancel before the relevant period ends. 7. Cancellation You may cancel a Premium Subscription only through the method authorised by TheScreeningCompany, the relevant payment processor, or the applicable account functionality. Unless otherwise stated at checkout or required by law, cancellation prevents future renewal charges only and does not entitle you to any refund for the current billing period or any prior period already charged. TheScreeningCompany may require account or identity verification before processing a cancellation request where reasonably necessary to prevent unauthorised cancellations. You remain responsible for all charges properly incurred before cancellation takes effect. 8. Billing Disputes and Chargebacks If you believe that a charge was made in error, you must first submit a good-faith billing dispute to TheScreeningCompany through the designated support channel, together with sufficient supporting information. Unless mandatory law requires otherwise, any billing dispute must be raised within 30 days of the charge first appearing. Failure to do so may result in waiver of the dispute to the fullest extent permitted by law. You agree not to initiate or support any chargeback, reversal, refund request, payment dispute, or retrieval action in relation to a valid charge, except where you genuinely and reasonably believe that the payment was unauthorised or processed in error. If you initiate a chargeback or reversal contrary to these Premium Terms, TheScreeningCompany may suspend your account, suspend active services, refuse future service, and recover all reversed sums, processor fees, administrative costs, collection charges, and legal expenses to the fullest extent permitted by law. Where lawful and proportionate, TheScreeningCompany may also claim a fixed administrative fee of up to EUR 750 per demonstrably unfounded complaint, claim, or dispute, and up to EUR 1,500, or such other amount lawfully specified elsewhere in the governing contractual framework, for abusive or bad-faith chargeback activity. 9. Refunds and Discretionary Credits Except where mandatory law expressly requires otherwise, TheScreeningCompany is under no obligation to provide any refund, reimbursement, adjustment, credit, or partial repayment in relation to any Premium Service. Any refund, credit, or goodwill adjustment granted shall be entirely discretionary, may be subject to conditions, shall not amount to an admission of liability, and shall not create any precedent or expectation in any future case. Where a specific refund window, trial cancellation right, cooling-off arrangement, pro-rated adjustment, or promotional reimbursement right is expressly offered at checkout for a particular Premium Service, only that specific arrangement shall apply and only in accordance with the exact conditions disclosed at that time. 10. Screening Outputs and Applicant Responsibility Any Screening Report or Premium Service output depends materially on the truthfulness, completeness, legality, and quality of the information and documents submitted by you. TheScreeningCompany does not guarantee that any Screening Report will be complete, exhaustive, continuously up to date, free from technical limitation, acceptable to any Provider, or sufficient to replace further checks required by a Provider. You are solely responsible for reviewing the accuracy of your information before submission and for ensuring that all uploaded documents are genuine, lawful, legible, unaltered, and properly authorised. TheScreeningCompany is not liable for any Provider rejection, repeated screening request, additional Provider requirement, request for further documents, delay, or decision to disregard any Screening Report. Any Premium Service that extends the visibility, duration, or availability of a Screening Report does not guarantee ongoing Provider acceptance, continuing legal relevance, or perpetual commercial value. 11. Account Security and Communications You are responsible for maintaining the confidentiality and security of your account credentials, devices, verification links, and communications associated with your account. Any activity carried out through your account shall be treated as authorised by you, unless mandatory law provides otherwise. You must notify TheScreeningCompany without undue delay if you suspect unauthorised access, credential compromise, fraud, or account misuse. You agree that TheScreeningCompany may send transactional, legal, billing, status, workflow, security, and service-related communications electronically, and that such communications satisfy any legal requirement for writing. 12. Company Rights to Modify or Withdraw Services To the fullest extent permitted by law, TheScreeningCompany may modify, suspend, restrict, replace, reconfigure, remove, discontinue, or withdraw any Premium Service, feature, workflow, or part of the platform at any time for legal, technical, security, anti-fraud, operational, compliance, or commercial reasons. TheScreeningCompany may also restrict access where reasonably necessary for maintenance, integrity protection, identity verification, payment verification, fraud prevention, legal compliance, migration, or operational stability. TheScreeningCompany shall not be liable merely because any part of the Services is unavailable, delayed, interrupted, altered, restricted, or withdrawn, except where mandatory law provides otherwise. 13. Prohibited Conduct You must not: submit false, forged, manipulated, misleading, incomplete, or unlawful information or documents; impersonate another person or use another person’s account; interfere with the integrity, security, or availability of the Services; introduce malicious code, bots, scripts, viruses, or harmful materials; reverse engineer, scrape, copy, extract, harvest, or exploit the platform, workflow structure, templates, algorithms, or screening logic; misuse any Premium Service in a fraudulent, abusive, unlawful, or commercially exploitative way; or make false, misleading, defamatory, or unsubstantiated public statements wrongly attributing an unfavourable third-party outcome to TheScreeningCompany. Where such conduct is reasonably suspected, TheScreeningCompany may suspend or terminate access, refuse service, invalidate the relevant workflow, report the matter where lawful, and pursue any contractual or legal remedy available to it. 14. False Claims and Public Misrepresentation You agree not to make, publish, repeat, or promote any false, misleading, defamatory, unsubstantiated, or materially inaccurate statement concerning TheScreeningCompany, the Services, or any Screening Report. This includes statements suggesting that an unfavourable Provider decision was caused by TheScreeningCompany where that claim is inaccurate, misleading, or unsupported. To the fullest extent permitted by law, where TheScreeningCompany reasonably concludes that such statements have been made, it may seek recovery of its reasonable administrative, legal, enforcement, and reputational mitigation costs, including any fixed administrative amount lawfully specified elsewhere in the governing contractual framework. 15. Disclaimer of Warranties To the fullest extent permitted by law, the Services, including all Premium Services, are provided on an “as is” and “as available” basis and without any representation, warranty, or guarantee of any kind. TheScreeningCompany disclaims all express, implied, statutory, or other warranties, including as to merchantability, fitness for a particular purpose, title, non-infringement, accuracy, completeness, uninterrupted availability, security, reliability, or Provider acceptance. TheScreeningCompany does not warrant that the Services will be uninterrupted or error-free, that defects will be corrected, that the platform will be free of harmful code, or that any output will meet your expectations or achieve any particular result. 16. Limitation of Liability To the fullest extent permitted by law, TheScreeningCompany shall not be liable for any indirect, consequential, incidental, special, exemplary, punitive, reputational, or emotional losses, or for any loss of profit, revenue, opportunity, goodwill, business, or data. In particular, TheScreeningCompany shall not be liable for: Provider decisions, refusals, or delays; inaccuracies or omissions in Applicant-submitted information; processor or payment failures; internet or technical disruptions; account misuse; regulatory or procedural consequences arising from Applicant conduct; or dissatisfaction with the usefulness, timing, or outcome of any Premium Service. To the fullest extent permitted by law, TheScreeningCompany’s total aggregate liability arising out of or in connection with any Premium Service shall not exceed the greater of: EUR 20; or the amount paid by you for the specific Premium Service giving rise to the claim. Nothing in these Premium Terms excludes or limits any liability which cannot lawfully be excluded or limited. 17. Indemnity You agree to indemnify, defend, and hold harmless TheScreeningCompany and its officers, directors, employees, affiliates, agents, contractors, licensors, and service providers against all claims, losses, liabilities, penalties, damages, costs, expenses, and reasonable legal fees arising out of or connected with: your breach of these Premium Terms; false, misleading, unlawful, forged, or infringing submissions; misuse of the Services; breach of law or third-party rights; payment disputes or chargebacks initiated by you; false public statements or reputational harm caused by you; or any Provider or third-party claim arising from your conduct or submissions. This indemnity survives termination. 18. Termination You may stop using the Services at any time, but doing so does not cancel accrued fees, recurring charges already properly incurred, or liabilities arising before termination. TheScreeningCompany may suspend, restrict, disable, or terminate your access to any Premium Service or account where it reasonably believes that you have breached these Premium Terms, engaged in fraud, misused the Services, submitted misleading information, or created legal, reputational, operational, or compliance risk. Upon termination, your right to access the affected Premium Services ends immediately, but all provisions intended to survive termination shall remain in effect. 19. Governing Law and Disputes Unless mandatory law requires otherwise, these Premium Terms and any non-contractual obligations arising out of or in connection with them shall be governed by the laws of Switzerland. Any claim, complaint, or dispute concerning these Premium Terms, Premium Services, billing, renewals, reversals, or related matters must first be raised directly with TheScreeningCompany in good faith through the designated support channel. Where formal proceedings are initiated by the Applicant, and to the extent permitted by law, such proceedings may be submitted and administered through the World Intellectual Property Organization (WIPO) in accordance with its applicable rules and procedures, if and insofar as that mechanism is relied upon under TheScreeningCompany’s governing dispute framework. To the fullest extent permitted by law, the Applicant shall bear all filing fees, administrative charges, procedural expenses, legal costs, and related costs. If any such claim is found to be invalid, inadmissible, unfounded, abusive, or unsubstantiated, the Applicant shall remain liable for all resulting costs, including their own costs, WIPO costs, and TheScreeningCompany’s reasonable legal and administrative costs. 20. General These Premium Terms, together with all incorporated legal documents, constitute the entire agreement in relation to Premium Services. TheScreeningCompany may assign, transfer, subcontract, delegate, or novate its rights and obligations without your consent. You may not do so without prior written consent. If any provision is invalid or unenforceable, the remainder shall remain in full force. No failure or delay by TheScreeningCompany in enforcing any right shall amount to a waiver. Any provision intended to survive termination shall remain effective, including those relating to payment, renewals already incurred, disputes, chargebacks, disclaimers, liability limits, indemnities, and governing law. 21. Express Confirmation by Proceeding By proceeding with any Premium Service, you expressly confirm that: you have read and understood these Premium Terms in full; you understand that payments are generally final and non-refundable except where mandatory law requires otherwise; you understand that Premium Services may involve recurring billing and automatic renewal unless properly cancelled; you accept full responsibility for all information and documentation submitted by you; you understand that TheScreeningCompany does not control Provider outcomes and does not guarantee acceptance of any Screening Report; and you agree to be legally bound by these Premium Terms.

1. Introduction and Scope of This Privacy Policy

This Privacy Policy (“Privacy Policy”) governs the collection, use, processing, storage, disclosure, retention, and protection of personal data by Capita Screening, acting as the data controller and, where applicable, as a data processor, in connection with the provision of its digital identity, financial, compliance, verification, screening, reporting, and optional premium services (collectively, the “Services”). This Privacy Policy applies to all Applicants, users, visitors, and account holders (“Applicant”) who access or use the Capita Screening websites, platforms, applications, interfaces, screening tools, reports, or related services, regardless of whether such use is free, trial-based, paid, premium, direct, indirect, mandatory, optional, or provider-requested.

This Privacy Policy is designed to reflect a Privacy by Design and Privacy by Default framework and is drafted to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as well as any applicable national implementing legislation, regulatory guidance, and supervisory authority interpretations. Where local laws impose additional or stricter obligations, those obligations shall apply concurrently. This Privacy Policy must be read in conjunction with any service-specific notices, screening disclosures, or supplemental privacy statements issued by Capita Screening, all of which form an integral part of the privacy framework governing the Services.

2. Legal Basis, Regulatory Framework, and Compliance Architecture

Capita Screening processes personal data strictly in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability. All processing activities are grounded in one or more lawful bases under Article 6 GDPR, including but not limited to the Applicant’s explicit consent, the necessity of processing for the performance of a contract or pre-contractual measures, compliance with legal obligations, and the legitimate interests of Capita Screening or third parties, except where such interests are overridden by the Applicant’s fundamental rights and freedoms.

Where special categories of personal data may be processed as part of enhanced screening, compliance, or verification workflows, such processing shall only occur where strictly necessary, proportionate, and permitted by law, and shall be subject to heightened technical and organizational safeguards. Capita Screening reserves the right to adapt its compliance framework dynamically to reflect evolving regulatory interpretations, supervisory authority guidance, case law, or statutory amendments, without diminishing the level of protection afforded to Applicants.

3. Categories of Personal Data Collected and Sources of Data

• Identification and account-related data, including account identifiers, authentication credentials, verification tokens, and communication preferences
• Contact data, such as email addresses or phone numbers, where voluntarily provided or required for verification, security, or compliance purposes
• Financial and banking data strictly limited to verification and validation purposes, including bank account identifiers used for micro-transaction validation (e.g., one cent verification)
• Screening-related data submitted directly by the Applicant, including uploaded documents, declarations, confirmations, selections, and responses
• Technical and security-related data, such as device metadata, anonymized analytics, temporary IP data, and authentication logs, where applicable
• Payment and subscription-related metadata processed via third-party payment service providers

All personal data is obtained either directly from the Applicant, generated through interaction with the Services, or received from lawful third-party verification sources strictly within the scope of the screening request.

4. Website Visits, Analytics, and Technical Operation

When visiting Capita Screening-operated websites or interfaces, Capita Screening may collect limited technical data necessary to ensure functionality, security, and performance. Analytics are implemented through self-developed or locally hosted tools designed to avoid unnecessary tracking, profiling, or identification. Wherever feasible, data is anonymized or aggregated at the earliest possible stage, and IP addresses are not retained beyond what is strictly necessary for security, abuse prevention, or regulatory compliance.

Capita Screening does not engage in behavioral advertising, cross-platform tracking, or unauthorized third-party analytics sharing. Any cookies or similar technologies used are limited to essential operational purposes unless otherwise explicitly consented to by the Applicant.

5. Account Creation, Authentication, and Verification Measures

Applicants may create an account using either a Capita Screening-issued identifier or an external email address. The creation of an account does not, in itself, require the disclosure of extensive personal data beyond what is necessary to establish account integrity, security, and lawful operation. External contact details, if provided, are used exclusively for authentication, recovery, security notifications, service-related communications, and legally permissible informational messages.

To protect the Services from abuse, fraud, automated attacks, or unauthorized access, Capita Screening employs human verification mechanisms, including captchas, email verification, SMS codes, and similar safeguards. Any data processed for such verification purposes is retained only for the minimum period necessary and, where retained longer, is stored in hashed or otherwise cryptographically protected form.

6. Screening Data, Bank Account Verification, and Reporting

As part of the screening process, Applicants may be required to submit financial, identity, or verification-related data. Bank account verification may involve a nominal micro-payment (e.g., one cent) solely for the purpose of confirming account ownership and validity. Such financial identifiers are processed within secured database environments employing encryption, access controls, and audit mechanisms consistent with industry best practices.

Screening reports generated by Capita Screening are based exclusively on data provided by the Applicant, third-party verification responses, and predefined processing rules. Capita Screening does not guarantee outcomes, acceptance, approval, or suitability determinations, as these remain subject to provider-specific criteria and external decision-making processes beyond Capita Screening’s control.

7. Communications and Correspondence

Communications between the Applicant and Capita Screening, including support inquiries, document requests, workflow updates, and service notifications, may be stored for quality assurance, dispute resolution, legal defense, compliance verification, and operational continuity. By using the Services, the Applicant consents to receive electronic communications related to account status, screening progress, required actions, payment confirmations, and security notifications. Such communications are deemed legally effective and equivalent to written notices.

8. Premium Services, Subscriptions, and Payment Processing

Where Applicants elect to subscribe to optional Premium Services, Capita Screening may process additional interaction data necessary to evidence informed consent, subscription acknowledgment, and awareness of non-refundable terms. Payment processing is conducted exclusively through third-party payment service providers, and Capita Screening does not store full payment instrument details. Only transaction metadata strictly necessary for reconciliation, compliance, and audit purposes may be retained.

Capita Screening reserves the right to delete obsolete or invalid payment-related data in accordance with data minimization principles and applicable financial record-keeping obligations.

9. Recording of User Selections, Consent Evidence, and Transactional Acknowledgments

By registering for, accessing, or participating in the Screening Process through Capita Screening’s mobile, web-based, or otherwise made available digital environments, the Applicant expressly acknowledges and agrees that Capita Screening processes and securely records technical, transactional, and interaction-based data evidencing the Applicant’s selections, confirmations, and affirmative actions throughout the screening registration and screening workflow.

Such processing includes, without limitation, the recording of which service options, screening pathways, and service tiers (including any optional Premium Services) have been selected by the Applicant, as well as the Applicant’s explicit acceptance of the applicable Privacy Policy, Terms and Conditions, Premium Terms of Service, and any related notices or disclosures presented at the time of selection. These acceptance records are stored in secured database environments using appropriate technical and organizational safeguards and are retained for the purposes of compliance verification, auditability, fraud prevention, dispute resolution, and legal defense.

The Applicant expressly acknowledges that the recorded selections, acceptances, and confirmations constitute conclusive evidence of the Applicant’s informed and voluntary decisions and agrees that the Applicant bears sole responsibility for all choices made, options selected, and authorizations granted during the screening and registration process. This includes, without limitation, acknowledgments relating to the activation of Premium Services, authorization of payments or recurring charges, and the acknowledgment of the non-refundability and irrevocability of transactions.

The processing and retention of such data is carried out on the basis of the Applicant’s consent, the necessity to perform requested services, and Capita Screening’s legitimate interests in maintaining service integrity, ensuring legal compliance, preventing fraud, and defending against claims, disputes, or regulatory inquiries.

By accepting this Privacy Policy, you expressly acknowledge, confirm, and agree that such acceptance applies to and includes all sections, clauses, and sub-clauses of this Privacy Policy, each of which shall be binding upon you.

9.1. Voluntary Selection of Premium Services and Consent-Based Processing

Certain enhanced or Premium Services offered by Capita Screening are optional, non-standard, and provided only where expressly selected by the Applicant. The activation of any Premium Service requires a deliberate, affirmative action by the Applicant and is never enabled automatically, implicitly, or by default. Where an Applicant elects to activate such Premium Services, Capita Screening processes personal data relating to that selection on the basis of explicit consent, performance of a requested service, and legitimate interests, including compliance verification, fraud prevention, billing integrity, and legal accountability.

By selecting a Premium Service, the Applicant acknowledges that the decision is voluntary, informed, intentional, and taken with full awareness of the applicable pricing model, recurring nature (if applicable), non-refundability of payments, and the corresponding data processing activities required to administer, evidence, and defend that selection. Capita Screening processes and retains confirmation records solely to demonstrate lawful consent, user intent, and transactional validity.

9.2. Processing of Subscription Data, Recurring Billing, and Payment Authorization Records

Where Premium Services are structured as subscriptions, Capita Screening processes subscription-related personal data necessary to administer recurring access, billing cycles, renewal events, and cancellation status. Subscriptions renew automatically at the conclusion of each billing period unless the Applicant actively terminates the subscription using the designated cancellation mechanism. Processing of subscription data is based on contractual necessity and legitimate interests in maintaining service continuity, payment accuracy, and auditability.

By initiating a subscription, the Applicant expressly authorizes Capita Screening and its designated payment service providers to process payment-related data and to charge the selected payment method for all applicable fees, taxes, transaction costs, and ancillary charges in accordance with the chosen plan. Capita Screening does not determine or control payment authorization outcomes and is not responsible for charges incurred due to the Applicant’s failure to maintain valid payment credentials or to cancel in a timely manner.

9.3. Trial Periods, Verification Charges, and Conversion Event Processing

Where Capita Screening offers a trial period or nominal verification charge (including but not limited to a one-cent authorization), personal data relating to such trials is processed exclusively for service evaluation, payment method validation, fraud prevention, and compliance documentation. Trial-related processing may include authorization holds, temporary charges, or verification transactions performed by payment service providers, which may affect available balances or credit limits.

The Applicant acknowledges that any trial period, where offered, automatically converts into a paid Premium Service unless cancelled prior to expiration. Data relating to trial commencement, expiration, conversion, and billing initiation is processed and retained as evidence of user awareness, consent, and lawful transaction execution. Verification and authorization charges are non-refundable by nature and do not constitute refundable payments.

9.4. Cancellation Requests and Data Processing Consequences

Applicants may terminate an active Premium Service only through the designated cancellation mechanism identified as “Stop Premium Service.” Upon receipt and processing of such a request, Capita Screening records the termination event and ceases future renewals. However, cancellation does not affect the lawfulness of prior processing, nor does it generate any entitlement to refund, reimbursement, credit, or reversal of previously processed payments.

All personal data relating to charges incurred prior to the effective termination timestamp may be retained to the extent necessary for accounting, dispute defense, regulatory compliance, and legal enforcement. Cancellation affects future access only and has no retroactive financial or data-processing effect.

9.5. Irrevocability of Payments and Exclusion of Refund-Related Processing

All payments processed in connection with Premium Services are final, non-refundable, non-creditable, and non-reversible. To the maximum extent permitted by applicable law, Capita Screening does not process, support, or facilitate refunds, partial refunds, credits, paybacks, or payment reversals under any circumstances, including dissatisfaction, non-use, partial use, mistaken activation, early termination, failure to cancel, third-party decisions, or perceived lack of suitability.

By proceeding with payment, the Applicant explicitly acknowledges and accepts that payment-related personal data will not be processed for refund evaluation or reversal purposes. The Applicant further acknowledges that any attempt to initiate a chargeback or payment dispute through external financial institutions constitutes a deviation from the agreed processing framework and may trigger additional data processing for enforcement, defense, and fraud prevention.

9.6. Chargeback Events, Fraud Detection, and Defensive Data Processing

In the event that an Applicant initiates or attempts to initiate a chargeback, reversal, or unauthorized payment dispute, Capita Screening may process and retain relevant personal data under its legitimate interests in fraud prevention, financial risk mitigation, and legal defense. Such processing may include the retention and disclosure of transaction records, interaction logs, timestamps, confirmations, and other evidentiary materials to payment processors, financial institutions, dispute resolution bodies, or competent authorities, strictly to the extent necessary.

Chargeback-related events are classified as high-risk financial incidents. Accordingly, Capita Screening reserves the right to restrict, suspend, or terminate account access and to retain associated personal data for the duration required to resolve disputes, recover costs, and comply with regulatory obligations.

9.7. Retention of Consent Evidence and Transactional Proof

For accountability purposes under data protection law, Capita Screening may retain records demonstrating the Applicant’s affirmative actions, consent acknowledgments, subscription selections, pricing disclosures, non-refund awareness confirmations, button interactions, timestamps, and related technical metadata, including IP-derived information where lawfully permitted. Such retention is limited to what is necessary to demonstrate compliance with legal obligations, defend against disputes or claims, and prevent fraudulent or abusive conduct.

This processing is strictly purpose-bound and does not constitute profiling, excessive retention, or unrelated secondary use.

10. No Waiver, No Precedent, and Reservation of Data Protection and Legal Rights

Any tolerance, exception, or discretionary action exercised by Capita Screening in an individual case shall not constitute a waiver of this Privacy Policy, shall not create precedent, and shall not give rise to future expectations or obligations. Capita Screening reserves all rights to process personal data as permitted by law for enforcement, compliance, dispute resolution, and protection of its legal and financial interests, in conjunction with other applicable policies and contractual frameworks.

11. Data Retention and Storage Limitation

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, including screening completion, reporting, compliance, dispute resolution, legal defense, and statutory obligations. Retention periods may vary depending on the nature of the data, contractual relationships, regulatory requirements, and legitimate interests. Upon expiration of applicable retention periods, data is securely deleted, anonymized, or rendered inaccessible.

12. Data Disclosure and Legal Requests

Capita Screening discloses personal data only where legally required by binding requests from competent authorities within applicable jurisdictions. All such requests are carefully reviewed for legal validity, proportionality, and jurisdictional competence. Where permissible, Capita Screening reserves the right to challenge or seek clarification of requests and to exhaust available legal remedies prior to disclosure. Under no circumstances does Capita Screening decrypt encrypted content or provide access beyond what is legally mandated.

13. Applicant Rights

Applicants have the right to access, rectify, erase, restrict, object to, or request portability of their personal data, subject to legal limitations. These rights may be exercised through account interfaces or by contacting Capita Screening. Where an account has been suspended or restricted, requests will be handled in accordance with applicable law. Applicants also retain the right to lodge a complaint with a competent supervisory authority.

14. Security, Risk Allocation, and Limitation of Liability

Capita Screening implements technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration. However, no system can be guaranteed to be fully secure. The Applicant acknowledges that data submission occurs at the Applicant’s own risk and that Capita Screening shall not be liable for damages resulting from circumstances beyond its reasonable control, including sophisticated cyberattacks, third-party failures, or force majeure events.

15. Amendments to This Privacy Policy

Capita Screening reserves the right to amend this Privacy Policy at any time within the limits of applicable law. Updated versions will be made available through the Services. Continued use of the Services following publication of changes constitutes acknowledgment and acceptance of the revised Privacy Policy.

TheScreeningCompany 1. Introduction and Acceptance These Conditions of Use govern your access to and use of the website, platform, mobile interface, screening environment, and related services provided by TheScreeningCompany (the “Services”). By accessing, registering for, or using any part of the Services, you confirm that you have read, understood, and agree to be legally bound by these Conditions of Use. Acceptance may be given electronically, including by creating an account, proceeding through the workflow, clicking to accept, or submitting information. If you do not agree, you must not, and are not allowed to use the Services. You also agree with the Privacy Policy and other Terms on this Website and KYC Screening Process services. 2. Legal Capacity and Responsibility By using the Services, you represent and warrant that: you are at least 18 years old; you have full legal capacity to enter into a binding agreement; and all information, documents, and data submitted by you are provided lawfully and with proper authority. All actions taken within the Services, including data entry, document upload, confirmations, selections, consents, and submissions, are made voluntarily and at your sole responsibility. TheScreeningCompany is not liable for user errors, misunderstandings, incorrect selections, unintended submissions, or any failure by you to read or understand the process. 3. Accounts, Access, and Security Accounts are personal, non-transferable, and must not be shared, sold, or used by any third party. You are solely responsible for safeguarding your login credentials, authentication details, verification links, devices, and other access tools. Any activity carried out through your account shall be treated as authorised by you unless mandatory law provides otherwise. TheScreeningCompany is not liable for any loss, damage, or misuse arising from compromised credentials, insecure devices or communications, or the sharing of account access with any third party. You agree to receive communications electronically, including legally binding notices, confirmations, and service updates. 4. Nature of the Services TheScreeningCompany provides a screening facilitation and reporting service designed to collect, process, structure, and present Applicant-provided information in a screening report. The Services may include automated checks, manual review, consistency indicators, formatting tools, and optional verification workflows. TheScreeningCompany does not make decisions, approve or reject applications, or guarantee outcomes. All decisions remain solely with the relevant third-party Provider. The Services do not constitute legal, financial, or other professional advice. You are responsible for obtaining independent advice where required. 5. Applicant Responsibilities You represent and warrant that all information submitted by you is true, accurate, complete, current, and not misleading. You accept full responsibility for any consequence arising from incorrect, incomplete, fraudulent, misleading, or unlawful submissions. Where you submit third-party data, you confirm that you have the necessary lawful authority and any required consent to do so. Your use of the Services is entirely at your own risk. 6. Technical and Security Risks You acknowledge that use of internet-based services involves risks, including interception, unauthorised access, system vulnerability, and external security breaches. You are solely responsible for the security of your device, network, internet connection, and communications. To the fullest extent permitted by law, TheScreeningCompany is not liable for hacking incidents, network vulnerabilities, or other external security events beyond its reasonable control. 7. Screening Process and Limitations The screening process is procedural in nature and depends materially on the information and documents submitted by you. TheScreeningCompany may suspend, restrict, or terminate the process where information is incomplete, inconsistencies arise, or fraud or misuse is suspected. Any screening report reflects a snapshot at a particular time and may become outdated. 8. Payments Certain Services may require payment in advance. All payments are final and non-refundable, except where mandatory law requires otherwise. This applies regardless of outcome, including where a report is rejected by a Provider, results are unfavourable, or your expectations are not met. Payment is made for the screening process and related administrative and technical services, not for any guaranteed result. 9. Prohibited Conduct You must not: submit false, fraudulent, manipulated, or unlawful information or documents; impersonate another person; misuse the Services or use them unlawfully; interfere with platform functionality; or reverse engineer, extract, copy, or exploit any part of the Services or related systems. Any breach may result in immediate suspension, termination, refusal of service, and legal action where appropriate. 10. Liability TheScreeningCompany is not liable for Provider decisions, third-party reliance on any screening report, or failures of external systems. To the fullest extent permitted by law, TheScreeningCompany shall not be liable for any indirect, consequential, financial, reputational, or opportunity-based loss or damage arising from or connected with the Services. Nothing in these Conditions excludes or limits liability where such exclusion or limitation is unlawful. 11. False Claims and Reputational Protection You agree not to make, publish, or repeat any false or misleading statement concerning TheScreeningCompany or the Services. Where such false or misleading claims are made, TheScreeningCompany may, to the fullest extent permitted by law, seek recovery of an administrative fee of up to EUR 1,500, GBP 1,500, or the USD equivalent, together with any other lawful remedies available to it. 12. Disputes Any claim or dispute raised by you must first comply with the dispute framework applicable to the Services. Where provided for under the governing contractual framework, claims may be submitted through the World Intellectual Property Organization (WIPO) in accordance with its applicable procedures. To the fullest extent permitted by law, you shall bear all filing, procedural, legal, and related costs on a pre-paid and post-paid basis. If a claim is unsuccessful, invalid, or unfounded, you shall remain liable for your own costs, WIPO costs, and TheScreeningCompany’s reasonable legal and administrative costs. 13. Governing Law Unless mandatory law requires otherwise, these Conditions of Use and any non-contractual obligations arising from them shall be governed by the laws of Switzerland. Swiss legal principles may also be applied by TheScreeningCompany in relation to privacy, data protection, internal governance, and contractual enforcement, subject always to mandatory local law where applicable. 14. General These Conditions of Use form the entire agreement in relation to your use of the Services. If any provision is invalid or unenforceable, the remaining provisions shall continue in full force and effect. Any failure or delay by TheScreeningCompany in exercising a right shall not amount to a waiver of that right. Any provision intended to survive termination or cessation of use shall remain in effect. 15. Final Acknowledgement By continuing to use the Services, you confirm that you have read these Conditions of Use, understand your obligations, and accept full legal responsibility for your use of the Services. Failure to read these Conditions does not invalidate your acceptance of them.