Compliance Statement

1. Regulatory Framework

Talo Pay operates as a payment technology intermediary within South Africa's regulated financial ecosystem. All payment processing is conducted through authorised, regulated Payment Service Providers (PSPs). Our compliance obligations include:

Protection of Personal Information Act (POPIA)

Talo Pay processes personal information lawfully, minimally, and securely in accordance with POPIA (Act 4 of 2013). A designated Information Officer oversees all data protection obligations. See our Privacy Policy for details.

Financial Intelligence Centre Act (FICA)

Where required by law, Talo Pay conducts identity verification (KYC — Know Your Customer) on Workers registering to receive payments. This includes verification of identity documents and bank account ownership. Workers who fail to complete verification will not receive settled funds until verification is approved.

National Payment System Act (NPS Act)

All payment processing conducted through Talo Pay uses authorised participants in South Africa's National Payment System. Real-time interbank settlement is provided via PayShap, operated by BankservAfrica under the oversight of the South African Reserve Bank (SARB).

PCI-DSS

Talo Pay uses PCI-DSS Level 1 certified PSP partners for all card and payment data processing. Talo Pay does not store, transmit, or process raw card data. All cardholder data flows through approved, secure payment channels only.

Consumer Protection Act (CPA)

Talo Pay's services to individual Customers are provided in accordance with the Consumer Protection Act 68 of 2008. Customers have the right to receive accurate information about the payment process and to have their transactions processed fairly.

Electronic Communications and Transactions Act (ECTA)

These Terms of Service and all electronic agreements formed through the Talo Pay platform are valid and binding under ECTA (Act 25 of 2002).

2. Identity Verification (KYC/FICA)

Workers registering with Talo Pay to receive tips are required to complete identity verification before funds are settled to their bank account. This is a legal requirement under FICA to prevent money laundering, terrorist financing, and financial crime.

Verification may include:

• South African identity document (ID book, smart ID card, or passport)
• Proof of bank account ownership
• Selfie or liveness check (where required by the verification provider)

Talo Pay uses regulated, POPIA-compliant identity verification service providers. Verification data is handled securely and not retained beyond the period required by law.

3. PayShap & Real-Time Clearing

Tips collected through Talo Pay are settled directly into the Worker's personal South African bank account via PayShap — South Africa's real-time interbank payment clearing service, operated by BankservAfrica. PayShap operates under a regulatory framework established by the South African Reserve Bank.

Talo Pay does not hold or pool customer funds. Tips are settled in real time after Talo Pay's flat fee is deducted. There is no wallet, no escrow period, and no minimum withdrawal threshold.

4. Risk & Fraud Monitoring

Talo Pay continuously monitors transactions for signs of suspicious activity, including:

• Unusual transaction volumes or patterns
• Identity mismatches during verification
• Duplicate or unauthorised payment attempts
• Activity consistent with fraud, money laundering, or structuring

Suspicious transactions may be paused, investigated, or referred to the relevant regulatory authority. Talo Pay cooperates fully with the Financial Intelligence Centre (FIC), South African Police Service (SAPS), and other regulatory bodies as required by law.

5. Reversals & Refunds

Talo Pay's refund and reversal practices align with South African payment industry standards:

• Reversals occur before settlement is finalised and return the full tip amount including fees.
• Refunds occur after settlement; the tip amount is returned to the Customer but fees already processed by the PSP are not recoverable.

These practices follow the rules of the PayShap scheme and Talo Pay's PSP partners.

6. Reporting Obligations

Where required by law, Talo Pay may be obligated to report certain activities or information to:

• The Financial Intelligence Centre (FIC)
• The South African Reserve Bank (SARB)
• Card network schemes (where applicable)
• Other competent authorities as directed by South African law

Such reporting does not require Talo Pay to notify the affected user in advance where prohibited by law.

7. Contact

For compliance-related inquiries:
info@talopay.co.za
Talo Pay (Pty) Ltd, South Africa